Justia Civil Rights Opinion Summaries

The Supreme Court reversed the circuit court’s dismissal of Plaintiff’s complaint claiming wrongful discharge against the Wetzel County Commission and the Wetzel County Assessor on the basis that the Assessor was entitled to qualified immunity and that all of Plaintiff’s claims lacked merit, holding that the circuit court erred in granting the motion to dismiss all of Plaintiff’s claims.After Plaintiff was terminated from his employment, Plaintiff sued Defendants claiming wrongful discharge. The circuit court dismissed the case pursuant to W.Va. R. Civ. P. 12(b)(6). In reversing, the Supreme Court held (1) Plaintiff alleged sufficient facts to demonstrate that the Assessor and the Commission were his joint employers, and Plaintiff’s allegations were sufficient to overcome dismissal of the Commission as a party; (2) Plaintiff’s allegations preluded application of qualified immunity in the context of a motion under Rule 12(b)(6); and (3) Plaintiff sufficiently pled several causes of action for purposes of surviving a Rule 12(b)(6) challenge. View "Burke v. Wetzel County Commission" on Justia Law

The Supreme Court vacated the judgment of the superior court granting a motion brought by Defendant, the State Public Defender’s Office, for judgment on the pleadings regarding Plaintiff’s employment discrimination claims.Plaintiff in this case filed two complaints. In Nugent I, Plaintiff appealed an arbitration decision concluding that the Public Defender’s Office acted wth just cause when it terminated Plaintiff’s employment. Judgment entered in favor of Defendant on the basis that Plaintiff lacked standing to challenge the arbitration decision in court. In Nugent II, Plaintiff alleged unlawful employment discrimination. Defendant moved for judgment on the pleadings, arguing that res judicata barred Plaintiff’s discrimination claims. The hearing justice granted the motion, and final judgment entered in favor of Defendant on all claims. The Supreme Court vacated the judgment in Nugent II, holding that Nugent I was not a final judgment for purposes of res judicata because the consideration of Nugent’s standing did not reach the merits of Nugent I, and therefore, Plaintiff was not barred from seeking redress for her discrimination claims raised in Nugent II. View "Nugent v. State" on Justia Law

Plaintiffs, 11 minority firefighters who were laid off by Detroit in 2012 as part of a reduction in force (RIF) that followed the city’s bankruptcy, sued the city and their union, (DFFA), alleging a violation of Title VII of the 1964 Civil Rights Act, 42 U.S.C. 2000e. The district court rejected their claims on summary judgment, finding that only one Plaintiff had exhausted his administrative remedies to pursue a claim against the city, but that even on the merits, Plaintiffs failed to present direct evidence or to establish a prima facie case under the circumstantial evidence approach, which includes a heightened burden in a RIF. The court concluded that Plaintiffs could not establish that the DFFA breached its duty of fair representation. The Sixth Circuit agreed that 10 Plaintiffs failed to exhaust administrative remedies, that there was no direct evidence of discriminatory motive, and that Plaintiffs’ statistical evidence was not probative and did not establish a circumstantial case. The court reversed as to DFFA, holding that a prima facie disability discrimination claim against a union does not require that a plaintiff demonstrate that the union breached its duty of fair representation. View "Peeples v. City of Detroit" on Justia Law

Rosa Jensen and Linda Kerr sued their former employer, The Home Depot, Inc., (Home Depot), and their former managers at Home Depot for disability discrimination, wrongful termination, and eight other related claims. Home Depot and the managers (collectively, defendants) demurred to the first amended complaint arguing misjoinder of Jensen and Kerr (collectively, plaintiffs). The trial court sustained the demurrer without leave to amend, and dismissed plaintiffs’ lawsuit with prejudice. Jensen contended on appeal the trial court erred by dismissing her lawsuit because the court could have ordered severance. “It is an abuse of the trial court’s discretion to sustain a demurrer without leave to amend if there is a reasonable possibility the plaintiff can amend the complaint to allege any cause of action.” At trial court, the Court of Appeal found plaintiffs made no showing as to how they would amend their complaint to fix the misjoinder issue. Accordingly, the trial court acted reasonably in sustaining the demurrer without leave to amend because plaintiffs failed to meet their burden. However, leave to amend may be requested for the first time on appeal; plaintiffs fixed the misjoinder issue by dismissing Kerr. Because the misjoinder issue has been fixed, the Court of Appeal ruled the case may proceed. The judgment of dismissal, as it pertains to Jensen, was reversed. The trial court was directed to enter an order vacating its order denying leave to amend as to the first through seventh causes of action, and enter an order granting leave to amend. The trial court was also directed to deem the first amended complaint to have been amended due to the dismissal of Kerr. View "Jensen v. The Home Depot, Inc." on Justia Law

The Fourth Circuit affirmed the district court's denial of qualified immunity to defendants, the town manager and its director of public safety, regarding plaintiffs' alleged due process violations after plaintiffs were terminated from their employment with the Department of Public Safety based on the content of private text messages. The court held that defendants deprived plaintiffs of constitutionally cognizable liberty interests under clearly established law, and plaintiffs were not afforded due process of law. The court held, however, that the district court erred in holding that defendants were not entitled to qualified immunity as to plaintiffs' First Amendment claims. In this case, plaintiffs' evidence did not establish beyond debate that their interest in speaking freely outweighed the Department's interest in maintaining order and discipline. Therefore, the court reversed in part and remanded for further proceedings. View "Cannon v. Village of Bald Head Island" on Justia Law

The Honorable Michael J. Theile is a Michigan state-court judge. In 2020, the year of the next election for the seat he now holds, Theile will be 71 years of age. Because the Michigan Constitution and a statute prohibit a person who has attained the age of 70 from being elected or appointed to judicial office, Theile will not be eligible to run for re-election, Mich. Const. art. VI, section 19(3); Mich. Comp. Laws 168.411. The Sixth Circuit affirmed the dismissal of his complaint, in which he asserted a violation of the Equal Protection Clause and asked the court to dispense with rational-basis review of age-based classifications and adopt intermediate scrutiny. The court declined to reverse the settled precedent of the Supreme Court and of the Sixth Circuit mandating rational-basis review for age-based classifications and precedent identifying multiple rational bases for judicial age limitations. View "Theile v. State of Michigan" on Justia Law

The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against him based on his age, sex, and national origin.Matthew Jahnke, an employee of Deere & Co., worked as a factor manager at Harbin Works in Harbin, China under a contract with a Deere Chinese subsidiary. As discipline for Jahnke engaging in sexual relationships with two Chinese employees, Jahnke was ultimately removed as the factor manager, repatriated back to the United States, and assigned to a position of lesser authority and lower pay in Waterloo, Iowa. Jahnke filed suit under the ICRA. In its motion for summary judgment, Deere claimed that the ICRA did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa. The district court denied the motion. The Supreme Court reversed, holding (1) the ICRA does not apply extraterritorially; and (2) because Jahnke failed to show that either he or Deere was located within Iowa for purposes of the alleged discriminatory act, Jahnke had no claim under the ICRA. View "Jahnke v. Deere & Co." on Justia Law

Plaintiff, a police officer and former police union official, filed suit alleging that defendants violated his First Amendment right to freedom of speech by retaliating against him for criticizing management decisions by police officials. The district court ruled in favor of defendants. The Second Circuit held that plaintiff's union remarks were not made under his official duties as a police officer and thus he spoke as a private citizen for purposes of the First Amendment. However, Defendants Moran and Mueller were entitled to qualified immunity, and plaintiff failed to allege a plausible claim for municipal liability against the city. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Montero v. City of Yonkers" on Justia Law

Correct Care Solutions, LLC (CCS) terminated Alena Fassbender’s employment for violating CCS policy. Fassbender, who was pregnant at the time of her termination, argued she was terminated because CCS had one too many pregnant workers in Fassbender’s unit, which posed a problem for her supervisor. After review of the district court record, the Tenth Circuit concluded a reasonable jury could believe Fassbender’s version of events. Accordingly, the Court reversed the portion of the district court’s order granting CCS summary judgment on Fassbender’s pregnancy discrimination claim under Title VII of the Civil Rights Act of 1964, 42 U.S.C. secs. 2000e–2000e-17. However, the Court affirmed in part, finding no reasonable jury could believe Fassbender’s alternative claim that CCS terminated her in retaliation for reporting sexual harassment. View "Fassbender v. Correct Care Solutions" on Justia Law

The DC Circuit affirmed the district court's grant of summary judgment against plaintiff in an action alleging that his supervisors at the EPA discriminated against him because of his age, in violation of the Age Discrimination in Employment Act, 29 U.S.C. 621–634. The court held that there was no excuse for plaintiff's noncompliance with an EEOC regulation requiring a federal employee to contact a counselor within 45 days of the date of the matter alleged to be discriminatory. In regard to plaintiff's timely claims of age discrimination, the court held that he failed to establish that he suffered an adverse employment action where each of his claims did not cause objectively tangible harm of the sort that would render them adverse employment actions. In regard to the retaliation claims, the court held that plaintiff failed to show a causal connection between the reassignment of his agents and his protected activities. View "Drielak v. Pruitt" on Justia Law